Unlocking Secrets: The iPhone Encryption Battle

Memorandum of Points and Authorities - I. Introduction

In the hopes of gaining crucial evidence about the December 2, 2015 massacre in San Bernardino, California, the government has sought to search a lawfully-seized Apple iPhone used by one of the mass murderers. Despite both a warrant authorizing the search and the phone owner's consent, the government has been unable to complete the search because it cannot access the iPhone's encrypted content. Apple has the exclusive technical means which would assist the government in completing its search, but has declined to provide that assistance voluntarily. Accordingly, the government respectfully requests that this Court issue an order compelling Apple to assist in enabling the search commanded by the warrant.